1. What Information Do We Gather?
When you visit our Site, we gather information by using cookies that are essential to your ability to move around the Site and to use its features. A cookie is a text file containing small amounts of information that are downloaded to your device when you visit a website. Without these cookies, for example, you cannot access secure customer portals or buy products. (For more information, please see our Cookie Policy). On our Site, we track information such as the domain name and the name of the web page from which you entered our Site, and how much time you spend on each of our pages. We collect information that is combined with other users' information, such as how many times users click on each web page and the methods by which our Site was found. We may collect IP addresses and website usage information from you when you visit our Site. (An IP address is a number that is assigned to your computer when you are using your browser on the Internet.)

We also use cookies to deliver web content specific to you and to keep track of your preferences. Our cookies cannot pass viruses, harm your computer, or pass on private information such as an e-mail address without your consent. Cookies contain session identification numbers that allow our systems to recall previous sessions for authentication efforts and assemble information from our gathered data. You can configure your computer's browser to alert you when a site is attempting to send you a cookie and allow you to accept or refuse the cookie. Refer to our Cookie Policy to see how you can configure your browser to manage cookies, or you can visit the Network Advertising Initiative website here to get information about how to opt out of cookies.

2. What Do We Do with the Personal Information We Collect?
If you would like us to send you information, you will be asked to provide personal information such as your name, physical address, or e-mail address. The personal information we collect is used only for the purpose we state at the time of collection, and we only collect information that is relevant to that purpose. For example, we may use your e-mail address to provide you with other information that is relevant to your use of the Site. To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we "anonymize" the data, i.e., remove information that would confirm your identity. We will not use your personally identifiable information, however, to send commercial or marketing messages to you unless we have your consent or except as part of a specific program or feature for which you will have the choice of either opting in or opting out.

This Site does not collect personally identifiable information when you browse the Site and request pages from our servers unless you voluntarily and knowingly provide such information to us. This means that we will not know your name, your e-mail address, or any other personally identifiable information just because you browse the Site unless you:

access the Site from a link in an e-mail that we have sent to you; or

have created a profile and you either log-in to your account or choose to be remembered via your cookie, including on your web-enabled mobile device.

In these cases, we will know who you are based on the information you previously supplied to us. When you request a page from our Site, our servers log the information provided in the HTTP request header, including the IP number, the time of the request, the URL of your request, and other information that is provided in the HTTP header. We collect the HTTP request header information to make our Site function correctly and provide you the functionality that you expect to see. We also use this information to personalize content presented to you, better understand how visitors use our Site and how we can better tune it, its contents, and functionality to meet your needs. If we would like to use your personally identifiable information for an unrelated activity, we will first request your consent to do so. Finally, we strive to only use information that is accurate, complete, and current. Please see Section 6 below for how to correct your personal information.

3. Who Can Use the Information We Collect and How?
We may provide your information to third parties, or third parties may collect information from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested. By written agreement, these third parties are required to implement similar security measures and will process your information only as authorized by us to fulfill the service that they have been contracted to provide.

Other than those who act on our behalf and except as explained in this Policy, information you provide at this Site will not be transferred to unrelated third parties, unless we have your permission to do so. Please note, however, that personal information provided to this Site is subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.

We allow you to control the disclosure of your non-public personal information to third parties for the marketing of third-party products and services (i.e., your consent is required for disclosure). We must disclose information, when requested, to comply with court orders or subpoenas.

4. How Do We Protect the Personal Information We Collect?
Your privacy and the security of your personal information are important to us. We maintain and protect the security of our servers and your personal information. To secure the information we collect online, prevent unauthorized access, maintain data accuracy, and ensure only appropriate use of information, we have established appropriate physical, electronic, and management safeguards. We require user names and passwords to access sensitive data. Unless you authorize unencrypted transmission, we will use industry standard encryption methods to protect your data transmission.

5. How Do You Opt Out of Personal Information Sharing with Our Business Partners?
Other than agents who act on our behalf, the information you provide through our Site will not be transferred to unrelated third parties unless we have your permission to do so. You can also opt out of our marketing e-mails at any time by contacting us at
unsubscribe@actagroup.com or by sending us a post card to "OPT OUT," THE ACTA GROUP, 2200 Pennsylvania Ave., N.W., Suite 100W, Washington, DC 20037.

7. What Is Our Privacy Policy If You Are under 13 Years of Age?
We understand the importance of protecting the privacy of all individuals, especially the very young. We neither target nor sell our services to children under the age of 13, and we do not knowingly collect personal information from them. Subscribing to our online service is restricted to adults who are either 18 years of age or older or as otherwise legally defined.

8. What Happens When You Link to a Third-Party Website?
If you click on a link and go to another site, you will be subject to that website's privacy policy. If we conduct business with that website such that we need to exchange personally identifiable information, we will make sure that the business has a privacy policy just as protective as ours. We encourage you to read the posted privacy policy statement at any website before submitting any personal information at all.

9. What Happens When We Update Our Privacy Policy?
We may on occasion update our Policy. Your acceptance of any minor changes to this Policy is indicated by your continued use of our Services. If we make any material changes to our Policy, we will post a notice about the change at a prominent location on our Site. We encourage you to periodically review our Site and this Policy for any changes.

10. What Happens If We Sell Our Business?
While we do not anticipate it, every business nowadays should plan for the possibility that it might sell certain or all of its assets to another entity, merge with another entity, or that it might buy certain assets of another entity. If all or part of our business is sold, merged, or otherwise transferred to another entity, the personal information you have provided to us may be transferred as part of that transaction. We will take steps, however, to ensure that your personal information is used in a manner consistent with the provisions of our Policy.

11. What If You Have Questions?
If you have questions or concerns regarding this statement, you should first contact us via e-mail at
privacypolicy@actagroup.com.